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Report—Remedial Action Feasibility Page 20 <br /> Cutter Lumber—Western Lift Site <br /> GPE Project No 102 3 <br /> August 1,2003 <br /> 9.0 FEASIBILITY OF CORRECTIVE ALTERNATIVES <br /> 9.1 Natural Attenuation <br />' Quarterly groundwater monitoring has been conducted at this release site since early <br /> 1998 Examination of the groundwater monitoring data suggests that natural attenuation <br /> is degrading the contaminant plume albeit at a very slow rate Data from the peripheral <br /> wells (i e MW-8, MW-9, MW-10, & MW-11) seem to suggest that the total "footprint" <br /> or areal extent of the contaminant plume is decreasing A log-normal cross-plot of TPH- <br /> G concentration against the time (in years) since the wells were constructed was <br />' generated using Excel software A copy of the cross-plot is included as Cross-Plot 4 A <br /> projection was made for each of the three plotted wells as shown in the figure In the core <br /> of the contaminated area as represented by samples from MW-6, MW-7, and MW-8B, the <br /> Irate of natural attenuation seems to be much slower than that observed in the peripheral <br /> wells Over all, contaminant concentrations in these wells have decreased about 50 <br /> percent since the wells were constructed The well with the highest absolute <br /> concentration (MW-7) has, also exhibited the most rapid decline in contaminant <br /> concentration, apparently proportionally high levels of volatiles being destroyed The <br /> decline in this well has shown a marked decline in the rate of decrease in recent years <br /> The second-most impacted well, MW-8B has shown essentially no decline in <br /> contaminant concentration over the life of the project and MW-6 has exhibited a very <br /> • modest decline Taken as a whole, the data appears to suggest that it may take several <br /> decades to adequately mitigate the release if natural attenuation is used as the sole <br /> mitigation method While the data are not in close agreement it is clear that the time <br /> needed to for natural attenuation is unacceptably long Based on the rate of attenuation <br /> exhibited in the groundwater to date, and projecting forward, it appear that it may take at <br /> least an additional 25 for natural attenuation to progress sufficiently for a site closure to <br />' be considered possible <br /> Should the natural attenuation method of site mitigation be employed, no additional work <br />' would be completed except for continued groundwater monitoring It is likely that over <br /> this period of time it would be necessary to repair or replace some, or all, of these wells <br /> Assuming that groundwater monitoring costs $12,000 per year in constant dollars, the <br /> total cost of monitoring would be more than $300,000 <br /> 1 9.2 Soil Vapor Extraction <br /> The pilot vapor extraction test documented by this report clearly show that vapor <br /> extraction as a stand-alone corrective measure will not be effective in mitigating this site <br /> This is due to two primary reasons First, the vadose zone soil is so poorly transmissive, <br /> that vapor extraction would require very tight well spacing to achieve pneumatic contact <br /> with the entire impacted vadose zone Secondly, with the bulk of the contaminant mass <br /> lying 5 to 15 feet below the groundwater surface, vapor extraction would be unlikely to <br /> affect the deeper contamination under the best of circumstances The radius of influence <br /> 2937 Veneman Ave, ##11240 Geo-Phase Environmental Inc Phone(209) 569-0293 <br /> Modesto,CA 95356 Fax(209)569-0295 <br />